IRS Releases Proposed Section 892 Regulations; Private Equity Fund Investments By Foreign Government Partners Potentially Affected

2 November 2011
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Key takeaways:

  • IRS Proposed Regulations released today liberalize the existing rules regarding the exemption from U.S. tax of investment income derived by foreign governments, especially the rules relating to investments in partnerships.
  • These changes will likely facilitate investment by foreign government entities (including sovereign wealth funds) in private equity funds and other managed investment vehicles.